How Soon Hath Time! July 21 Deadline Looms For Investment Advisers But Grace May Be At Hand
The hasting days fly on with full career while the SEC proceeds with rulemaking to implement the Dodd-Frank Act’s changes to the regulation of investment advisers. Last week, Associate Director Robert E. Plaze in the SEC’s Division of Investment Management confirmed that the SEC intendes to complete required rulemaking by July 21, 2011 in this letter to David Massey, the President of the North American Securities Read more...
Commissioner Previews Potential Private Fund Adviser Rule Changes
If you’re reading this blog, then you had a better Ides of March than Julius Caesar did in 44 B.C.E. In this March 5 post, I reported that the Commissioner of Corporations would be seeking comments on proposed amendments to Rule 260.204.9. Yesterday, the Commissioner issued this Invitation for Comments. As discussed in several earlier posts, Rule 260.204.9 must be amended Read more...
Commissioner To Ask For Comments On Rule 260.204.9
Look for the Commissioner of Corporations to be issuing a solicitation for comments on proposed changes to Rule 260.204.9. As will be discussed in a Guest Blog to be posted on Monday, the Commissioner has announced that he is considering changes to Rule 260.204.9 in light of the enactment of the Dodd-Frank Act last summer. Currently, many private fund managers (including Read more...
California Commissioner Expresses Concern About Proposed Venture Capital Fund Definition
As I wrote in this early posting, California is ground zero for the venture capital industry. Many of our most succesful and innovative companies have been funded by the venture capital industry. Thus, it is good to see that Commissioner Preston DuFauchard has submitted this letter of comment with respect to the Securities and Exchange Commission’s proposed rule defining “venture capital Read more...
What is a Venture Capital Fund? (Part II)
The Securities and Exchange Commission has established a procedure for commenting on rule proposals even before the proposals have been made. I’ve already taken advantage of this procedure to submit this comment on with respect to the definition of “venture capital fund”. This process didn’t go well for me as the SEC somehow lost my comment. However, I’m pleased to say that Read more...
“Most” Does Not Mean All
Because the Dodd-Frank Act requires the adoption of so many new regulations, I like to say that the other shoe (or more likely a whole closet full of shoes) remains to be dropped. One large shoe that is yet to be dropped is how the Securities and Exchange Commission will define “venture capital fund” for purposes of the exemption from the Investment Advisers Read more...